ML20245D222
| ML20245D222 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/1989 |
| From: | Baker E, Naidu K Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245D213 | List: |
| References | |
| REF-QA-99900225 NUDOCS 8904280162 | |
| Download: ML20245D222 (13) | |
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ORGANIZATION: THE FOXBORO COMPANY .
-FOXBORO, MASSACHUSETTS REPORT INSPECTION INSPECTION NO.: 99900225/89-01 DATE: "ebruary 6-10, 1989 ON-SITE HOURS: 74 CORRESPONDENCE ADDRESS: Dr. Peter F. McCrea, Vice President, Research, 1 Design, and Quality Assurance "
The Foxboro Company Mail Stop No-2B Foxboro, Massachusetts 02035-2099 ORGANIZATIONAL CONTACT: S. Hasan Razvi, Corporate Quality Assurance Manager !
TELEPHONE NUMBER: 508-543-8750 l i
NUCLEAR INDUSTRY ACTIVITY: Pressure and differential pressure transmitters, !
level and flow transmitters, monitoring and actuating system panels. l
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ASSIGNED INSPECTOR:
K. R. Naidu, Reactive Inspection Section No. 1, Date (RIS-1)
OTHERINSPECTOR(S): T. J. Keck, Brookhave National Laboratories APPROVED BY: & T IM E. T. Baker, Chief, RIS-1, Vendor Inspection branch, D&te DRIS, NRR INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21,10 LFR 50, Appendix B.
B. SCOPE: Reviewed the problems with certain components received at RIT1 stone 2 nuclear potter plant; reviewed the implementation of the quality assurance program in selected areas; observed the. final assembly l and testing of one transmitter; reviewed the stetus of findings identi-fied in.NRC Inspection Report 99900225/85-01.
l PLANT SITE APPLICABILITY: Millstone 2(50-336), San Onofre (50-361;362),
DC Cook (50-315;316). !
I 8904280162 890425 OOb i
ORGANIZATION: THE FOXBOR0 COMPANY
. FOXBORD, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 2 of 13 A. VIOLATIONS:
No violations were identil ed during this inspection.
B. NONCONFORMANCES:
Contrary to Criterion V, of Appendix B to 10 CFR 50, " Instructions, Procedures, and Drawings," and paragraph 4.2 of The Foxboro Company (TFC) Corporate Quality Assurance (QA) Procedure 3.18.3, Revision C, dated October 27, 1986, the Nuclear Product Safety Subcommittee (NPSS) was not convened to evaluate the problems reported in repair order 88R-94760 concerning the evaluation of two N-2AX+SLM type safety-related printed circuit boards (PCBs). The PCBs, which had been recently furnished to Millstone 2 as safety-related components, were determined to be inoperable during receipt inspections at Millstone 2.
C. UNITES 0LVED ITEMS:
No unresolved items were identified during this inspection.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (Closed) Violation 85-01-01 The violation identified that TFC failed to evaluate a problem identified at San Onofre 1 in 1978 concerning the degradation of electrical conductor insulation of "E-Line" controllers and TFC failed to notify either the Nuclear Regulatory Consission (NRC) or the nuclear pcwe. plant customers as required by 10 CFR Part
- 21. During this inspection, the inspectors determined that the implementation of the steps taken to correct the violation, as outlined in TFC's letters dated May 28, 1986 and June 4,1986, were adequate.
- 2. (Closed) Violation 85-01-02 The violation identified that TFC's procedure for 10 CFR Part 21 evaluations was inadequate. Six instances where TFC did not perform deportability evaluations were provided. The inspectors determined that TFC established Procedure 3.18.3 to analyze product defects to determine if the 3erceived problems were generic. Copies of the letters to tieir customers on failures considered generic were made available for review.
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ORGANIZATION: THE FOXBOR0 COMPANY
- FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 3 of 13 i
Additionally, NPSS reviewed all the failure analyses reports generated during 1978 to 1988 and determined that none of the component failures were considered reportable according to 10 CFR l Part 21 requirements. The NRC inspector concurs with the TFC i conclusion.
- 3. (Closed)Nonconformance 85-01-03 The nonconformance identified that TFC did not provide indoctri-nation and training programs for engineering, design, testing, corporate quality assurance, customer service, or management personnel. The inspectors reviewed 16 randomly selected indoc-trination and training courses scheduled and performed in 1988.
No discrepancies were observed.
- 4. (Closed)Nonconformance 85-01-04 This nonconformance related to an inadequate procedure to notify the NPSS of conditions adverse to quality. The inspectors reviewed the current procedure and determined the procedure to be adequate,
- 5. (Closed) Nonconformance 85-01-05 The nonconformance identified that an outside calibration lab-oratory (ESSCo) was listed on the TFC approved Vendors List without any documented audit results. The inspectors reviewed the audit performed on ESSCo on June 16, 1986. No adverse observations were identified. ESSCO calibrates the prime stan-dards used by TFC to calibrate instruments in the Highland plant.
- 6. (Closed) Nonconformance 85-01-06 The nonconformance identified that 2 of the 18 instruments sampled had labels to indicate that the calibration was overdue.
During the plant tours of the Neponset and Highland plants, 53 instruments used for testing and calibration were checked for calibration due dates. No instrument was observed overdue for calibration. Two calibration standards located in the Neponset plant quality control test laboratory were selected and the calibration records were traced to the primary standards used in the Corporate Calibration Laboratory. The calibration records for the primary standards, which are calibrated by an outside
l ORGANIZATION: THE FOXBORO COMPANY l FOXB0RO, MASSACHUSETTS l REPORT INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 4 of 13- )
calibration laboratory, were reviewed. The' records included a 1 statement that the calibration standards were traceable to the j standards located at the National Bureau of Standards.
- 7. (Closed) Nonconformance 85-01-07 The nonconformance identified that internal audits were not performed quarterly for all stages of the manufacturing cycles. ;
The inspectors reviewed the 1988 Highland Plant audit schedule.
Forty-four of the 45 audits scheduled covering all stages of manufacturing cycles were completed. One scheduled audit was cancelled.
E. INSPECTION FINDINGS AND OTHER COMMENTS:
- 1. Review of TFC Repair Program The inspectors reviewed the TFC repair program to determine the circumstances under which two of the four N-2AX+SLM pressure signal limiter printed circuit boards supplied to Northeast Nuclear Energy Center (NNEC), the owners of Millstone 2 nuclear power station, failed to perform during receipt inspections at the site. Furthermore, NNEC identified considerable difficulty in sliding the PCBs into their frames, identified as TFC part number N-2AP. The pressure si the narrow range (0-1600 psig)gnal limiter pressurizer levellimits the signal to transmitter, which is normally overranged during power operations. The information regarding the defective PCBs was obtained from NRC !
Inspection Reaort 50-336/88-24, issued by NRC Region I office, docurrenting tie results of the resident inspector's inspection of Millstone Unit 2 from October 13 through November 23, 1968. NNEC purchase order (PD) 913894 to TFC included the supply of four -
N-2AX+SLM type signal limiter PCBs and four N-2AP type PCB holders. These items were supplied to NNEC in August 1988 with a certificate of conformance, dated August 23, 1988, certifying that the items comply with the P0 requirements and that the components were manufactured with the same materials and processes as those qualified for Class IE service as documented in TFC Qualification Report Q0AAB51, Revision A. Two of the four PCBs failed performance tests. All four of the PCBs were diffficult to insert into'the PCB holders. NNEC returned the two defective PCBs to NNEC. Repair documents indicate that one PCB had a short circuit and the other had a break in the foil on the PCB.
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ORGANIZATION: THE FOXBORO COMPANY '
FOXBOR0, MASSACHUSETTS l REPORT INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 5 of 13 The inspectors visited the Highland plant where these components are manufactured. The inspectors obtained a PCB and a PCB holder from stock and attempted to insert the PCB into the holder.
Considerable difficulty was experienced during insertion, due to a small 90-degree step where the PCB is guided into the slot of the PCB holder. Specifically, the problem was in the molded 30-pin connector identified as part number 8 on the assembly drawing NO300FZ, Revision R. Drawing C0154BS, Revision J, depicting the detail of part number 8 (connector) indicates a <
taper instead of a step. The inspectors discussed this subject with the cognizant individuals in the molding department, inspected the die used to mold the connector and determined that the problem was apparently caused by the die. TFC took corrective action by preparing Tool Order 120212-010 to correct the step in both cavities to provide the taper in the die.
The inspectors determined that the PCB holder problem had not been identified previously because these PCB holders are assembled in panels manufactured by TFC. The problem arises only when spare PCB holders are purchased to extend the capacity of the existing panels or replace individual PCB holders. The NRC is not aware of similar problems reported by any other nuclear power plant.
The inspectors observed that TFC did not convene the Nuclear Product Safety Subcommittee to evaluate the problems identified on the repair order (88R-94760) for the signal limiter PCBs, as required by Corporate QA procedure 3.18.3. The inspectors informed the TFC QA Manager that the failure to follow Procedure 3.18.3 is contrary to Criterion V of 10 CFR 50, Appendix B and is consisdered a nonconformance. (B9-01-01)
The inspectors determined from discussions with cognizant TFC individuals familiar with the manufacture of the signcl limiter PCBs that the terminals (tabs) of the potentiometers are required
! to be bent at a 90-degree angle after solder connections are completed. If the potentiometer tabc are not bent, the PCB holders cannot accommodate the PCB because of the extra height.
The inspectors determined that test technicians are required to l use Procedure 14400KF, Revision C to test the type signal limiters. TFC stated that the signal limiters supplied to NNEC were tested by a temporary trainee. The instructions to assemble the signal limiter PCBs have been subsequently revised to 1
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4 ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 6 of 13 ]
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I include a step which requires the potentiometer tabs to be bent l at a 90-degree angle.
- 2. Control of Design Drawings i j
All the drawings related to components used to assemble nuclear i safety-related instruments are stamped " Nuclear Safety Related."
Whenever such a drawing is to be revised, the drawing is accom-panied by a separate sheet of paper identified as the Revision Appendix (RA). The RA is initiated by the cognizant engineer describing the change and is approved by his supervisor. The drawing and the RA are then forwarded to the Corporate Drawing Control Department who in turn sends it to Corporate Quality Assurance (CQA) to concur with the design change if the change does not affect the arevious qualification of the equipment.
Paragraph 2.2.5 of t1e procedure for Corporate Engineering Standard (CES) 280:5q, Revision P, dated July 5, 1988, entitled,
" Revision Control Including Certified Products," describes this process. The inspectors reviewed the ras for drawings B0134MA, Revision B; C0131HN, Revision C; D0126VA, Revision T; and NO302MA, Revision C and determined that a CQA representative approved the change prior to final issue.
- 3. Review of the Processing of Purchase Orders
- a. Procedure for Processing The inspectors reviewed the processing of P0s issued by utilities for safety-related applications. TFC personnel stated that all P0s are entered J the local TFC sales office and subsequently electronically tran .citted to the pre-order entry office loc-ated at Robinson Hill, Foxboro. The order is stamped " Nuclear" ,
to alert other offices that the component is intended for use !
in a nuclear power plant and is forwarded to Nuclear Power Engineering (NPE). NPE prepares a folder for the order, identi-fies the specific documentation to be supplied with the com-ponent such as (1) calibration, (2) nuclear grade cleanliness (3)hydrostatictest,and(4)certificateof certificate,(C0C). A " Manufacturing Production Sheet,"
conformance which goes to the appropriate plant, is prepared and stamped
" nuclear." A Repair Purchase Order (RPO) is prepared to repair safety-related items. The RP0 is also stamped " nuclear."
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. . . j ORGANIZATION: THE FOXBORO COMPANY FOXBORD, MASSACHUSETTS REPORT INSPECTION ,
NO.: 99900225/89-01 RESULTS: PAGE 7 of 13 !
The item is sent to the clean room where all the safety-related instruments are assembled. The instrument to be repaired is disassembled, tested and the cause of failure is determined.
NPE conveys the cause of the malfunction and the. estimated cost to repair, to the customer and obtains his consent prior to performing the repair. NPE arepares the list of documents required and sends the RPO to tie clean room to get the instru-ment repaired.
TFC Engineering Operating Procedures (EOP) describing the above steps were available for review.
- b. Review of the Implementation of E0Ps.
The inspectors reviewed the TFC folders for the following RP0 and P0s:
(1) American Electric Power Service Corporation issued P0 05354-041-8X, dated August 25, 1988, for the supply of one N-E13DH-H1M2-B type differential pressure transmitter, calibrated for the range 0-150 inches of water, with a C0C stating that the component is identical to that tested in reports Q0AA C10 & 00AACII/Wyle Test Report 45592-4/QA-N.
(2) Southern California Edison Company (SCE) issued PO 6W128002, dated December 6, 1988, to TFC to repair a N-E13DM-IIM2J type differential pressure transn.itter with serial number 5147469. SCE stated in part that "the transmitter cannot be statically aligned with specification." implementation of the TFC quality assurance program was required. SCE regjested TFC to supply a C0C and a failure analysis report with the repaired transmitter.
(3) Northeast Nuclear Energy Company issued P0 913894, dated September 9, 1988, to repair two N-2AX+SLM type PCBs.
The inspectors determined that the E0Ps were complied with during the repair and manufacturing operations.
ORGANIZATION: THE FOXBORO COM"ANY FOXBORO, MASSACHUSETTS REPORT INSPECTION H0.: 99900225/89-01 RESULTS: PAGE 8 of 13
- 4. Plant Tours During the inspection period, the inspectors, accompanied by TFC personnel, toured the plants located at Neponset, Highland, and Cocassett and observed various activities in progress,
- a. Neponset Plant _
The pressure, differential pressure, level, and flow trans-mitters and indicating type instruments are assembled in this plant. The hardware components such as pressure boundary covers, force motor assembly parts, and plastic molded parts are manufactured in this plant. Other com-ponents, such as electronic PCBs manufactured at other TFC locations, are shipped to this plant for the final assembly of the transmitters.
The inspectors observed that in-process inspections were being performed at various locations where parts were being finished. A computer list provides information on the location of each purchased part and the number of items held in inventory in the warehouse.
- b. Highland Plant Electronic subassemblies such as amplifier boards and other PCBs are manufactured at this plant. A computer list was av.ailable at this locatior; which provided information on the lochtion and number of items available in inventory of purchased items, as well as finished components, such as, PCBs and PCB holders. The inspectors used this computer list to locate potentiometers installed in N-2AX+SLM type PCBs, the PCBs, and N-2AP type PCB holders.
- c. Cocassett Plant This plant manufactures panels to monitor the operation of various systems in nuclear power plants. Components manu-factured at the Neponset, Highland, and other locations are used in the assembly of the panels. " Spec 200 Micro" panels for use in safety systems at the Connecticut Yankee nuclear power plant and an "ATWS Mitigating Actuation Systems" panel
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ORGANIZATION: THE FOXBORO COMPANY f FOXBORO, MASSACHUSETTS )
REPORT .
INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 9 of 13 for the R.A. Ginna nuclear power plant were in various stages of completion.
- 5. Observation of Final Inspections The inspectors visited the clean room where instruments intended for nuclear power plants are assembled and tested. Instruments ;
requiring repair are also disassembled in the clean room.
Persons entering the clean room are required to wear clean coveralls including caps.
The inspectors witnessed the calibration of a N-E11 DMIIB2-BFL type differential pressure transmitter, serial number 5391270, ordered by the Connecticut Yankee nuclear power plant. The instrument was being calibrated to respond to -5 to 30 psi input pressure and produce a corresponding output signal of 4 to 20 milliamperes (mA). The purchase order documents were in a file identified " Nuclear Safety-Related." Other documents in the file for this instrument included the following:
- a. A " Nuclear Cleaning Certificate" stating that all process wetted parts were cleaned to Procedure CESA 264, dated February 1,1972. The procedure requires wetted parts to be cleaned with Acetone, rinsed with distilled water, blown dry with pre-purified nitrogen, and dried in an oven.
- b. A hydrostatic test report certifying that the enclosurc housing the wetted parts withstood 4500 psi for 10 minutes
. without leaks on January 13, 1989.
- c. A calibration data sheet, dated January 19, 1989, indicating that the instrument was calibrated to produce a 4-20 mA output signal in response to -5 to 30 psi input pressure.
- d. A Certificate of Conformance stating that the above instru-ment met the guidelines for IEEE 344-1975 for seismic qualification.
TFC stated that typically all the parts required to assemble a transmitter are sent to the clean room. After the assembly is completed, the transmitter, without the electronics, is soaked at 300*F for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to relieve stresses. A cover leak test is t performed on the transmitter for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at 90 psi. The i
l l , ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS l REPORT INSPECTION PAGE 10 of 13 NO.: 99900225/89-01 RESULTS:
transmitter assembly is then heated to 250 F and maintained at that temperature for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during which the 4 mA output signal at that ambient temperature is verified. The transmitter is expected to maintain the 4 mA signal during the subsequent cooling to ambient temperature. Final Acceptance Quality Program Checklist 10115PG is used to inspect the transmitter. All the applicable requirements for the specific transmitter are yellow lined to highlight the attributes to be verified.
- 6. Review of Control of Purchased Material
- a. Control of Material Traceability The inspectors selected the wetted cover for the E-13 series transmitter to review the traceability of purchased material.
This part is identified as Part No.141KB on Parts List 008-567. The corresponding forging number is No. 141KA, made of 316 type stainless steel raterial, ASTM-A-182 F316, with a maximum Rockwell Hardness of Rc 22. Ideal Forging, Southington, Connecticut, supplied 225 pieces to TFC to fill PO 506432, dated October 20, 1988. The receipt inspection checklist indicates that the receipt inspector (identified as QA stamp 042) inspected 225 pieces to drawing No. 141XC, Revision Z and rejected none. The certified material test report (CMTR) identifed heat number 87 42 071, heat code NN, and listed the tensile strength as 85,000 psi, the yield strength as 41,300 psi, elongation as 48 percent, and reduction in cross-sectional area as 69 percent. The CMTR provided the ladle analysis for the heat and certified that the material was solution annealed at 7900 F (minimum) and was water quenched to below 800*F in less than 3 minutes. This material was also certified to be free from mercury.
The inspection checklist attributes are: drawing revision symbol, visual configuration, workmanship (visual), wall thick-ness of 0.25 inches (measuremer.t), heat number and material type clearly stamped on each piece at locations identified on the drawing, CMTR, and other dimensions. TFC performs a 2-hour salt spray test and inspects the surface condition to see if it is free from iron or visible contamination. The inspectors accompanied by TFC QC personnel went to the storage area, located the area where these covers were
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ORGANIZATION: THE FOXBOR0 COMPANY
, FOXB0RO, MASSACHUSETTS REPORT li;SPECTION '
NO.: 99900225/89-01 RESULTS: PAGE 11 of 13 stored and examined them. The inspectors observed no adverse findings.
- b. Control of Qualified Components TFC initially qualified components manufactured by accept- l able vendors, such as resistors and diodes, used in the l manufacture of their electronic assemblies. These compo-nents were invariably used in the assembly which was sub-jected to equipment qualification tests. After the com-ponent is qualified by type numbers, TFC purchases these components from distributors. All components are inspected after receipt and a failure history is maintained. The inspectors randomly selected six components from the N-2AX+SLM drawing and established that these components were on the " qualified components list. The integrity of the individual componets are confirmed during the final tests.
- c. Control of Nonqualified Components TFC stated that there have been instances where they had to purchase nonqualified components to replace qualified ,
components which have been rendered obsolete. A noncon- '
formance report (NCR) is issued in such cases when the components are received. These components are stored in a segregated and controlled area. The performance of the components issued from this lot is continuously monitored and the failure rate is recorded. Components, with unsatisfactory performance, are returned to the vendor.
The inspectors reviewed the following NCR's generated by receipt inspection for such purchases:
(1) NCR 17773, dated December 7, 1988, identified that 0 1 of the 117 potentiometers (Part flo.197MB) received from Greenshaw, Incorporated per PO 931480H45A, were reported defecti/e during receipt inspection. It war subsequently oetermined thit the vendor had shipped the wrong potentiometers. Corrective action was to return them to the vendor.
(2) NCR 17695, dated Noverber 11, 1988, identified that 6500 pieces of part no. 282FJ (diodes originally
ORGANIZATION: THE FOXBORD COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.: 99900225/89-01 RESULTS: PAGE 12 of 13 manufactured by Fairchild) were purchased through a distributor, per P0 34102H46. The diodes were manu-factured 14 years ago. Three diodes failed electical tests at receipt inspection. Disposition of the jiCR recommended the return of the diodes to the vendor.
(3) NCR 15290, dated March 10, 1987, identified that 14 of the 146 integrated circuit boards, Part No. 4015, purchased from Harris Company per P0 926929107A, were defective. Disposition of'the NCR required the return of the 14 defective items and reevaluation of the vendor.
(4) NCR 18032, dated January 26, 1989, identified that 1 of 10 triplett indicating meters purchased to PO 931163H52B, did not meet the accuracy requirements.
Furthermore, receipt inspection observed that the pivot jewel movement was sticky and the pointer did not move freely. Corrective action taken wss to return the instrument to the vendor for replacement.
The inspectors consider the dispositions of the NCRs reviewed acceptable.
F. EXIT INTERVIEW: l The inspectors met with persons identified in Section F and discussed the scope and findings of the inspection. l Persons Contacted Neponset Plant I *Dr. P., F. McCrea Vice President, Research, Design, and ;
Quality Assurance >
- S. H. Fazvi M;. nager, Quality Assurance
- R. A. Anderson Senior Quality Assurance Engineer
- R. V. Porter Senior Quality Control Engineer J. Rinaldi Product Engineer D. Dicesare Quality Control Inspector W. Simpson Instrument Test Technician R. Rodier Supervisor, Molding M. Patel Molding Engineer
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ORGANIZATION: THE FOXBOR0 COMPANY FOXBORD, MASSACHUSETTS REPORT INSPECTION N0.: 99900225/89-01 RESULTS: PAGE 13 of 13 Highland Plant
- D. Golden Manager, Technical Services
- W. F. Griffin Supervisor, Quality Control M. Webb Quality Control Inspector G. Gaziano Quality Control Inspector, Procurement R. Bates Quality Control Supervisor, Procurement Cocassett Plant
- E. Morris Engineer, Nuclear Engineering
- J. R. Brikert Manager, Nuclear Engineering
- M. Van Dyne Supervisor, Repair Services
- Denotes those individuals who attended the exit interview on February 10, 1989.
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